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In 1985 New Zealand had a tax system that taxed corporate profits twice, first in the hands of the company and secondly in the hands of the shareholder, known as the “classical system”. The paper suggests how dividends from capital sources ought to be treated if this double taxation is to...
Persistent link: https://www.econbiz.de/10013038989
This paper considers New Zealand's hybrid tax credit system consisting principally of a credit system combined with exemption features in respect of certain classes of income, both of which aim to provide relief to minimise the impact of foreign income being taxed in a foreign jurisdiction as...
Persistent link: https://www.econbiz.de/10013038221
In the latter half of the 1980s the tax climate in Australia and New Zealand changed markedly. While throughout the …
Persistent link: https://www.econbiz.de/10013133720
The objector in Anzamco Ltd v Commissioner of Inland Revenue (1983) 6 NZTC 61,522 was a company that had bought and developed a farm and sold it at a significantly higher price. The Commissioner taxed the profits under paragraphs 67(4)(a) and (e) of the Income Tax Act 1976. The court allowed the...
Persistent link: https://www.econbiz.de/10013039055
If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...
Persistent link: https://www.econbiz.de/10013020030
If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially.In consequence, courts and scholars have adopted surrogate tests that they attempt to employ in place...
Persistent link: https://www.econbiz.de/10013036482
Tax treaties that have been concluded by common law countries follow the basic structure, concepts, and language of model tax conventions that were promulgated by the OECD in 1963 and 1977. Thus, clauses from most treaties concluded by most common law countries are equally suitable as...
Persistent link: https://www.econbiz.de/10013038946
intercept passive income, such as interest or royalties, that would otherwise be taxed to the shareholders. Secondly, by using a … accrue to the shareholders. Six countries, the United States of America, Canada, France, the Federal Republic of Germany, and …
Persistent link: https://www.econbiz.de/10013038992
From a tax policy point of view, one of the demerits of a foreign investment fund regime is that it causes the law to treat forms of investment that are similar in economic purpose and effect as if they were different. In particular, it I likely to distinguish between direct investments by...
Persistent link: https://www.econbiz.de/10013038829
The Taxation (Beneficiary Income of Minors, Service-Related Payments and Remedial Matters) Act 2001 taxes the income of most beneficiaries of trusts who are minors at 33 per cent. This measure responded to parents strategically diverting income to their children via trusts, with a view to that...
Persistent link: https://www.econbiz.de/10013038843